Associação Brasileira de Normas Técnicas (ABNT), the National Body representing Brazil, today filed an appeal to the approval of OOXML by ISO/IEC, bringing the current total of appeals to two, with as many as two additional appeals to come, based upon what I have heard from private sources. The text of the Brazilian appeal appears in full at the end of this blog entry, supplied by a trusted source in Brazil.
While this latest appeal overlaps the South African objections in part, it also raises new concerns, some of which are particular to the interests of Brazil, rather than applying to the process as a whole. As a result, it raises not only additional issues, but also ones that present a categorically different basis for appeal as well.
Brazil's objections fall under two main headings, the second of which was also raised by South Africa. That objection relates to the fact that the reconciliation draft of DIS 29500 that was delivered to ISO on March 29 still has not been released, even to the National Bodies. Despite the fact that this release has been requested by many different parties representing multiple viewpoints, no public or private explanation has thus far been given for the failure to follow rules calling for the releasee of the draft within 30 days of the close of the BRM.
The new issues fall under the second major objection, which the letter summarizes by stating that the results of the BRM wre "inconclusive." It supports that contention with a variety of examples, including:
1. The fact that the Brazilian delegation was not permitted to present a proposal regarding legacy binary mapping
2. Repeated refusals to address requests and issues due to lack of time
3. Decisions were mandated by lack of time, lead, leading to decisions Brazil deems "to completely incompatible with the kind of decisions that should have be taken."
4. Decisions taken based upon an asserted "need to give answers to journalists"
5. Misuse of limited time for irrelevant purposes
6. Misapplication of the rules relating to who was entitled to vote in the BRM (a point also raised in the South African appeal)
7. Votes taken without prior discussion
8. Recourse to block voting not because it was an adequate approach, but only because it was "less bad"
9. An error relating to an objection in the official notes of the meeting
Each of these assertions is explained in detail, giving specific instances of conduct taken (and not taken) at the BRM. The ABNT appeal concludes its first argument by highlighting the fact that only 189 out of 1027 responses were actually discussed at the BRM, and stating "For the above-mentioned reasons, Brazil considers that the ISO/IEC DIS 29500 BRM was inconclusive."
Whether or not this latest appeal will be rejected out of hand or allowed to become the subject of serious consideration remains to be seen. Presumably some of the examples given above will receive scant attention, given that ISO was represented at the meeting, and participated in the decision making that lay behind the key decisions made at the time. But with each additional appeal that is filed, one would hope that a review of the process will be found to be more urgent, given the evident unhappiness of National Bodies that attended the BRM in good faith, and left unsatisfied not with the result, but what they had witnessed in the course of a long and frustrating week in Geneva.
Here is the text of the letter from ABNT in Brazil:
Dear Sirs,
The Associação Brasileira de Normas Técnicas (ABNT), as a P member of ISO/IEC/JTC1/SC34, would like to present, to ISO/IEC/JTC1 and ISO/IEC/JTC1/SC34, this appeal for reconsideration of the ISO/IEC DIS 29500 final result.
This appeal is based on two main considerations:
1. Brazil considers that the BRM was inconclusive.
2. Brazil considers that the final version of the ISO/IEC DIS 29500 text shall be released immediately.
1. About the BRM
At the BRM, the Brazilian delegation was not allowed to present an important proposal regarding the legacy binary mapping. This proposal was a complementary part of USA delegation proposal regarding the new organization of the ISO/IEC DIS 29500. It also shall complement the scope change proposal approved at the BRM.
Brazil has tried to present this proposal, during the debates, on the first day of the meeting and, attending to a request made by the convenor, Brazil has taken offline discussions with USA and other delegations and prepared its proposal to be presented on Friday, during USA proposal presentation.
On Friday, when USA ended their part of presentation and asked for Brazil to present its part of it, the convenor denied this opportunity to Brazilian delegation.
Several delegations has protested against that arbitrary decision, but those appeal was in vain and until the end of the BRM, the Brazilian delegation was not able to present its proposal. The main reason alleged by the convenor was “lack of time”.
The proposal here mentioned, is the one available on the file “Br_Multipart_Proposal.ppt” available to all BRM members the ISO/IEC/JTC1/SC34 website at least since the fourth day of the meeting.
Brazil also noticed that most of the decisions taken during the BRM were based on the “lack of time” argument, and we think that this is completely incompatible with the kind of decisions that should have be taken on that meeting.
During the BRM, some decisions were also taken based on the argument that “we need to give answers to journalists”, and we think that the media coverage of that meeting was not so important as the meeting results, to be used as a decision making criteria.
Even with the “lack of time” alleged, some members of ECMA delegation, and not members of any NB, was allowed to do half-hour speeches during the two first days of the meeting.
The voting rules of that meeting were not taken in accordance with ISO/IEC/JTC1 directives subclause 9.1.4. Brazil also notes that the ISO/IEC DIS 29500 was voted under ISO/IEC/JTC1 but the BRM was organized by ISO/IEC/JTC1/SC34. Even if the directives subclause 9.1.4 was intended to be used, Brazil cannot understand if the P member status considered, should be the ISO/IEC/JTC1 or the ISO/IEC/JTC1/SC34 one.
Brazil also considers that if most part of the issues was to be decided by vote, without any kind of discussion allowed.
About the same subject, Brazil considers that the elected “default voting criteria” was only elected because it was the “less bad” criteria that could be analyzed, and we do not consider that this voting decision represents the intent of the vast majority of BRM delegates. They went there to discuss the technical propositions.
Analyzing the document “SC 34 N 990 – EDITED NOTES OF THE MEETING”, on page 7, we have found the register of BR objection to the multi-part split decision but analyzing the document “SC 34 N 989 – RESOLUTIONS OF THE MEETING” we do not find that objection registered.
During the BRM, the delegations were asked to vote in block for the rejection of a set of responses that was considered by the convenor as “responses without any editing instructions”. Those responses are listed on the file “dis29500-nochange.txt”, available at the SC34 website during the BRM and, as far as Brazilian delegates remember, this set of responses was “rejected in block” as requested.
When we analyze the documents N989 and N990 we do not see any reference to that decision and also at the ISO/IEC/JTC1/SC34 document with title “Result of Proposed disposition of comments (SC 34 N 980)”, that presents a table with the status of each response, some of the “block rejected responses” appears as accepted (e.g. responses 3, 5, 10 and 11 among others).
To finalize our considerations about the BRM, analyzing the document N 989, we’ve found that the BRM can be summarized by:
Total of responses available for discussion: 1027 – 100 %
Total of responses addressed at the BRM: 189 – 18,4 %
Total of responses decided by “default” vote: 838 – 81,6 %
We use the term “responses addressed at the BRM” above because the majority of those responses was decided by block vote without any discussion at the BRM.
For the above-mentioned reasons, Brazil considers that the ISO/IEC DIS 29500 BRM was inconclusive.
2. About the final version of ISO/IEC DIS 29500 text
According to the directive item 13.12, the final version of the ISO/IEC DIS 29500 text shall be distributed on not more than one month after the end of the BRM.
Seen that almost three months has passed after the end of BRM, without any final version of the text distributed or published, and based on directive subclause 13.12, Brazil request the distribution of ISO/IEC DIS 29500 final text.
For all those reasons presented, Brazil kindly request that the final result of ISO/IEC DIS 29500 should be reconsidered by ISO/IEC/JTC1 and ISO/IEC/JTC1/SC34.
Best regards,
Marcia Cristina de Oliveira
ABNT – Manager Standardization Process
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It is incorrect that the Brazilians describe the vote as a default vote as most countries actually submitted only individual approval votes for a lot of responses.
However it is a fact that both Brazil and South Africa agreed at the BRM with the the form vote procedure and following that agreement at the BRM themselves gave a default disapproval vote on most responses even if the country that submitted the original issue voted for approval of the response.
Their appeals about the BRM procedure are poor when it actually shows that they voted for approval on the form voting procedure and used that procedure to try and disapprove as many issues as they could and are now, after this strategy has failed, are protesting the BRM procedings.
> It is incorrect that the Brazilians describe the vote as a default vote as most countries actually submitted only individual approval votes for a lot of responses.
Actually, it is incorrect that the BRM so-called vote was a vote at all. Likewise it is incorrect to say the BRM had a conclusive result.
If there is any substance to the Brazilian comments about their (or anyone else’s objections not getting registered/recorded in the minutes and about comments/objections not being heard or discussed at the BRM for any reason other than lack of merit, then there really were no choices made at the BRM at all. All choice was removed before the BRM started when the convenor decided to present to the BRM only 4 non-acceptable solutions – each of which reduced or eliminated discussion and consensus-building – to choose from while withholding the choice of "decide that we cannot reach consensus after 5 days and let the DIS fail" which is specifically called out as an option in the JTC1 directives.
That there was concern about the "journalist response" by the convener and that this was used as an excuse to not build consensus is a clearly inappropriate reason for the BRM to ignore or suppress any technical concern or proposal (especially constructive and co-dependent proposals) from the NBs.
Confusion (either at the BRM -or- after the BRM and once the JTC1 directives had been studied) over which members should have been allowed to vote and which voting rules to apply, should be clear indication that the BRM convener had not done his homework and that all results of the BRM are suspect if not outright invalid due to invalid procedures.
For the official minutes of the BRM to fail to record proposals made during the BRM and to fail to record official protests made during the BRM clearly indicates that the BRM agenda was not neutral but was heavily slanted toward achieving a particular result.
To accuse BRM members of ‘sour grapes’ because they took part and voted against a rigged decision to the extent they were allowed to ‘vote’ at all is simple dishonesty. The only choices presented as ‘voting options’ during the BRM were the magnitude of the approval margin that the ECMA recommendations would have at the end of the BRM – not whether the recommendations would be accepted/rejected.
That is not a vote. That is a sham.
These countries actually all voted APPROVAL on the procedural matters at the BRM.
Why claim to be protesting in if you vote to approve the procedures (oh wait, mayby because they hoped to get a negative voting result)
You know what, this is ridiculous. All the issues in the process, all politics, everything leads to expose how ISO conduct is not reliable.
Probably it was like this since ever, in all standardization processes in ISO, but only the popular OOXML process exposed this ISO mess to the world.
By the way, I have friends that have more experience dealing with ISO and they told me they are bureocrats exposed to lobby all the time. So again, what is written in a process rules document (as JTC1 Fast Track) really doesn’t matter much. And probably many standards we use today were defined this way, not because they are good, but because somebody pushed them down to the throat through ISO.
ISO is not reliable anymore.
Avi Alkalay
IBM Brazil
Memeber of the team that analyzed OOXML in ABNT